In order to address possible avoidance of the connected party market value rules (see C2.110), special provisions apply where, within a period of six years, a person makes a series of disposals to a person or persons with whom they are connected. In the normal way, each transaction would be treated as made for a consideration equal to the market value of the asset at the time of transfer. The provisions are intended to counter avoidance of tax where the market value of the total transactions, taken together, exceeds the total of the market values of the individual transactions1. Common examples could be a set of antique furniture or pictures, or a substantial holding of ordinary shares in an unquoted company.
Recomputation of market value
The market value of a disposal is recomputed to be for a consideration equal to the appropriate portion of the aggregate market value where 2:
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•ÌýÌýÌýÌý where there are a series of transactions ie two or more material transactions, or gifts, between two or more connected
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